DPDP Consultant

DPDP Act Consulting

Our Lead DPDP Act consultant has worked on DPDP Act implementation across all major business verticals

• Banking & Financial Services:

  Banks, NBFCs and insurance companies are subject to the DPDP Act's most demanding obligations since they process financial personal data in large volumes and manage consent for KYC/AML and credit workflows. The banks and NBFCs also need to comply with RBI's overlapping data protection guidelines.

  Our DPDP Act Consulting experience for banks and financial services spans

  • Designing consent management aligned with new customer onboarding journeys(NTB customers)

  • Consent management for existing customers (ETB/KTB customers)

  • Advising on Data Fiduciary classification for co-lending and wealth management entities, and

  • Mapping DPDP notice requirements against existing IRDAI and RBI Fair Practices Code mandates.

• Fintech / Payment aggregators:

  Payment aggregators and fintech platforms process millions of personal and financial data records to facilitate transactions for banks, merchants, and end-users. Hence, these entities act as both Data Fiduciaries and Data Processors that demand extensive review of their data processing operations.

  Our DPDP Consultant's experience in this vertical includes

  • Structuring DPDP-compliant data sharing agreements between aggregators and partner banks,

  • Advising on consent architecture for recurring payment mandates, and

  • Aligning RBI PA/PG guidelines with DPDP notice and purpose-limitation obligations.

• e-Commerce & Retail:

  E-commerce platforms are the one of the highest-volume processors of personal data in India. The personal data processing includes behavioral data like browsing behaviour and purchase history along with delivery addresses, and payment information. For e-Commerce and retail businesses, purpose limitation and data minimization are central to DPDP Act compliance.

  Our DPDP Consulting work in this sector covers -

  • Redesigning consent flows for personalisation and marketing,

  • Advisory on children's data safeguards for platforms with minor users, and

  • Structuring data-sharing frameworks with third-party logistics, sellers, and advertising partners that are Data Processors.

• Software-as-a-Service & IT Services:

  DPDP Act Consulting is critical business development need for SaaS and IT services companies. These entities normally act as Data Processors for their customers (Data Fiduciaries). Hence, the data fiduciaries demand that these entities demonstrate their technical security and organizational measures for data protection along with data processing agreements, and sub-processor management programmes.

  Our DPDP Consultant's experience in this vertical includes

  • Advising SaaS providers and IT services companies on positioning their DPA clauses,

  • Building privacy-by-design controls into product development lifecycles, and

  • Designing breach notification workflows

  • DPDP gap assessments for delivery centres

  • Advising on cross-border data transfer implications, and

  • Embedding DPDP contractual obligations into master service agreements for vendors/sub-processors.

• Artificial Intelligence:

  AI systems' training data often contains personal data collected without explicit AI-use consent. Automated profiling or decision-making complicates the implementation of valid consent, purpose limitation, and data minimization mandates.

  Advisory experience in this sector covers

  • Conducting AI-specific Data Protection Impact Assessments,

  • Advising on lawful basis and consent architecture for training data pipelines,

  • Helping AI product companies design disclosure mechanisms where automated processing significantly affects individuals, and

  • Anticipating Significant Data Fiduciary obligations expected under upcoming DPDP Rules.

• Data Labeling Ecosystems:

  Data labelling businesses are typically Data Processors annotating personal data on behalf of their clients. Simultaneously, these data labeling companies can also be Data Fiduciaries if they are collecting and personal data for further labeling and selling as data sets.

  Consulting experience here includes designing

  • Consent frameworks compliant with the Act,

  • Structuring client data-processing agreements that clearly delineate fiduciary and processor roles, and

  • Advisory on data minimization practices to reduce the volume of identifiable information exposed to annotators.

DPDP Consultant Expertise

• Data Privacy Risk Management

• DPDP Act 2023 Readiness & Implementation

• Design and implement Privacy Operating Model

• Cross-regulatory mapping (DPDP Act vs. GDPR)

• Harmonization of Privacy controls with controls from other frameworks like ISO 27001, NIST, PCI-DSS

• Data Lifecycle Management

• Data Minimization and Purpose Limitation

• Data Processor Governance & Third-Party Risk management

• Guidance on Sensitive Personal Data Handling (SOGI Data, Financial Data)

• Stress Testing & Scenario Planning for Data Risk

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DPDP Act Consulting - Success Stories

The Largest Foreign Bank in India

One of the largest multinational banks has engaged the consultant for oversight on the privacy program of the Bank. The existing privacy program of the Bank was closely aligned with EU-GDPR. One of the objectives of the consulting engagement was to identify similarities and divergences between the DPDP Act and EU-GDPR and hence understand the compliance maturity level. Other objectives included reviewing personal data collection mechanisms including consent and choice, data protection impact assessment, data minimization.

Key contributions included:

• Gap Review & Regulatory Validation: Reviewed and validated the DPDP gap assessment report delivered by a big-4 audit firm, ensuring accuracy and completeness from a regulatory and risk management standpoint.

• Translation of Legal Mandates: Translated DPDP obligations into technical and organizational measures for the First Line of Defence (1LoD), aligning operational controls with regulatory expectations.

• Data Asset Mapping: Identified and documented critical assets across on-premises and multi-cloud environments that process personal data.

• Governance Representation: Performed the role of Data Protection Officer and lead the meetings of the Bank’s Privacy Working Group, influencing governance outcomes and cross-functional compliance priorities.

• Executive Advisory: Guided non-technical business leaders across Retail Banking, Wholesale Banking, Investment Banking, and Market Services on regulatory principles such as purpose limitation, data minimization, valid consent, and lifecycle management.

• Comparative Legal Analysis: Delivered a structured comparative study of GDPR vs. DPDP Act, highlighting areas of convergence, divergence, and potential regulatory risk.

• Target Operating Model Design: Defined roles, control owners, and operators to establish a scalable privacy governance structure.

• Control Effectiveness Oversight: Reviewed data risk controls and monitored Key Control Indicators (KCIs) for ongoing compliance assurance.

• Sensitive Data Handling: Developed recommendations for HR on lawful collection and processing of SOGI (Sexual Orientation and Gender Identity) data.

• Stress Testing Framework: Helped in Designing stress-test scenarios for adverse data risk events (1-in-25-year and 1-in-100-year probabilities) to assess resilience of the Bank’s data risk posture.

A Government Entity

The consultant was engaged to assess and strengthen the privacy practices in the voice data collection initiative led by a department under a ministry of the government of India for AI training datasets in regional Indian languages.

Key contributions included:

• Privacy Compliance Audit: Reviewed consent collection processes for alignment with DPDP Act requirements and best practices in informed consent.

• Intellectual Property & Licensing: Evaluated IP rights and voice data licensing (Creative Commons framework) for compliance with ownership and usage rights.

• Vendor Risk Management: Reviewed and redrafted data processing agreements with third-party vendors, ensuring compliance with fiduciary obligations.

• On-ground Privacy Assessment: Conducted field visits to voice data collection centres to verify adherence to privacy and ethical data collection norms.

• Due Diligence Advisory: Advised DesiCrew on contractual due diligence when engaging with major data fiduciaries.

• Privacy Capacity Building: Designed and delivered a live training program for over 50 project leads, focusing on the practical aspects of the DPDP Act and responsible data handling.

Looking for a DPDP Act Consultant?

DPDP Consulting

Manage data risk. Design and operationalize data privacy controls for compliance with the DPDP Act.

Outsourced Data Protection Officer support to manage privacy compliance and regulatory obligations under the DPDP Act

Data Protection Impact Assessment of data-processing risks to ensure lawful, secure, and transparent handling of personal data.

DPO as a service

DPIA